Guidelines and Requirements for Shipping Chemicals

The shipment of hazardous chemicals, infectious agents, some clinical specimens, formaldehyde, and dry ice is regulated by the Department of Transportation and other regulatory agencies. If you ship any of these materials, documented training is required. Training on shipping all of these materials EXCEPT hazardous chemicals is provided in the EHSO DOT Shipping Biological Materials course available at https://www.ouhsc.edu/ehso/training/new_logon.asp (HSC and Tulsa employees) and https://www.ouhsc.edu/ehso/training-norman/new_logon.asp (Norman employees).

Information on the regulations, requirements, and prohibitions of shipping all other hazardous chemicals is provided below. If you are currently shipping hazardous chemicals, contact your campus EHSO immediately so that we can verify and assist with compliance with these requirements.

Department of Homeland Security (DHS)

New DHS Chemical Facility Anti-Terrorism Standards require facilities storing or shipping certain chemicals to identify the facility and the chemicals through a registration with DHS, prepare Security Vulnerability Assessments, which identify facility security vulnerabilities, and to develop and implement Site Security Plans. Because of these regulations, shipping ANY QUANTITY of the following chemicals requires compliance with these requirements, and therefore shipment of these chemicals by University employees is prohibited unless prior arrangements are made and approved by the EHSO.

OSHA Federal Hazard Communication Standard (29 CFR 1910.1200

If a University employee ships a hazardous chemical the University/employee becomes a "distributor".

A hazardous chemical is defined as either a health hazard or a physical hazard. For detail, see the OU Hazard Communication Program for definitions of health hazard and physical hazard. To summarize these definitions, "hazardous chemicals" includes just about every chemical in a laboratory except for buffers and water.

Excerpts of the OSHA requirements for distributors shipping hazardous chemicals are provided here:

Labeling

1910.1200(f)(1) "The chemical manufacturer, importer, or distributor shall ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked with the following information:

(i) Identity of the hazardous chemical(s);
(ii) Appropriate hazard warnings; and
(iii) Name and address of the chemical manufacturer, importer, or other responsible party."

MSDSs

1910.1200(g)(7)(i) "Distributors shall ensure that material safety data sheets, and updated information, are provided to other distributors and employers with their initial shipment and with the first shipment after a material safety data sheet is updated."

1910.1200(g)(7)(ii) "The distributor shall either provide material safety data sheets with the shipped containers, or send them to the other distributor or employer prior to or at the time of the shipment."

Excerpts of the Oklahoma Department of Labor Hazard Communication Standard requirements for shipping chemicals are provided here:

380:45-3-3. MSDS and labeling chemicals provided by research laboratories to other employers

(a) Laboratory employers that ship hazardous chemicals developed by that laboratory to another employer are considered to be either a chemical manufacturer or a distributor under this rule, and thus must ensure that any containers of hazardous chemicals leaving the laboratory are labeled with:

(1) Identity of the hazardous chemical(s);
(2) Appropriate hazard warnings; and
(3) Name and address of the chemical manufacturer, importer, or other responsible party.

(b) In addition, an MSDS shall be provided which shall comply with 29 CFR 1910.1200(g)(1)-(6).

United States Department of Transportation (DOT)

The DOT is a United States Federal agency which regulates the transport of hazardous materials to, from or through the United States. DOT regulations are found in part 49 of the Code of Federal Regulations (49 CFR), are enforceable by law, and can carry significant fines and other penalties for failure to comply. These regulations and requirements apply to anyone who, with respect to dangerous goods or hazardous materials:

• Offers for transport
• Transports
• Causes dangerous goods to be transported
• Loads/unloads transport vehicles or aircraft
• Determines the hazard class of a hazardous material
• Selects or fills a hazardous materials packaging
• Secures a closure on a filled or partially filled hazardous materials package
• Marks or labels a package to indicate that it contains a hazardous material
• Prepares a shipping paper
• Provides and maintains emergency response information
• Reviews a shipping paper to verify compliance with the Hazardous Materials Regulations or international equivalents
• Manufactures and/or tests packaging materials for dangerous goods use

Such persons are considered by DOT to be Hazmat employees.

International Air Transport Association (IATA)

The IATA Dangerous Goods Regulation (DGR) is the industry standard for transporting dangerous goods by air. While IATA is not a federal or international regulatory agency, in general, unless the IATA DGR is followed for the air transport of dangerous goods, air carriers will not accept the shipment. IATA does not apply to packages that are shipped exclusively by ground transportation.

Both DOT and IATA have specific training requirements for persons who package and ship hazardous materials.

DOT requires initial training for hazmat employees who prepare packages for shipment which includes general awareness/familiarization, function-specific, security awareness and safety training.   Recurrent training is required every three years.

IATA requires similar training, but recurrent training is required every two years.

This training must be coordinated with the EHSO, since routine sessions are not regularly provided.

The University of New Hampshire has developed guidance documents which may assist with understanding the requirements for shipping chemicals at http://www.unh.edu/ehs/pdf/UNH-Shipping-Hazardous-Materials.pdf and http://www.unh.edu/ehs/pdf/Small-Quantity-Exceptions.pdf, however, reading these documents does not substitute for the training requirements.

If you have any questions, contact your campus EHSO.

This file was updated on: 1/23/09 . Any comments or suggestions should be forward to the Environmental Health and Safety Office.

Every effort will be made to update the information contained on these pages as necessary. However, it is the responsibility of the user to determine that he or she is relying on the most current version of any particular information. Any questions about the material should be directed to the referenced office or department.